My name is Alison Goebel and I am the Executive Director of the Greater Ohio Policy Center (GOPC), a nonpartisan, nonprofit with a mission to champion revitalization and sustainable growth in Ohio. Thank you for accepting formal comments on the state mitigation plan for the Mitigation Trust Fund association with the Volkswagen Consent Decree.

You may recall that GOPC submitted a recommendation in December 2016 during the first public comment period requesting that Ohio EPA provide 50% of the proceeds from the settlement be spent to repower and replace diesel vehicles in Ohio’s public transportation fleet. As we noted at the time, public transportation in Ohio has been severely underfunded for years. Currently the state allocates approximately $0.63 per Ohioan to transit, while Ohio’s peers, such as Pennsylvania and Michigan, invest over $24.00 per capita. Half of Ohio’s allotment ($35.7 million) of the Mitigation Trust Fund could replace more than 125 diesel-powered city buses, or repower more than 700 buses with alternative fuel engines.

GOPC has had the opportunity to review the Draft Beneficiary Mitigation Plan and a representative of our organization attended the public information session hosted in Columbus on January 11. We wholeheartedly endorse the draft plan recommendation that 45-50% of the settlement be spent on on-road fleet and equipment projects, with 20% of the total settlement ($15 million) allocated for the replacement of transit buses and 20% for school bus replacement.

GOPC believes that using the settlement funds for transit vehicles is the highest and best use of the Mitigation Trust Fund dollars.

The eight largest public transportation systems serving Ohio EPA’s possible priority counties provided more than 105 million rides in 2015. If transit ridership rates remain the same over the ten year life of the Mitigation Trust Fund, Ohio will potentially avoid more than 1.05 billion automobile rides.

Eliminating emissions from outdated diesel transit engines and substantially contributing to the reduction of individual automobile emissions will have extraordinary and compounding benefits for Ohio’s air quality.

Greater Ohio is pleased to support the Draft Beneficiary Mitigation Plan and is encouraged to hear that there may exist and opportunity for additional funds available under the draft plan to be reallocated towards on-road fleet and equipment projects in the future.

Thank you for the work that you have put in to developing this draft plan. GOPC fully supports this proposal.